Last Updated: 1 October, 2024
Susumi Capital Index Ltd. and its affiliates (collectively, “Susumi,” “we,” “us,” or “our”) are committed to protecting the privacy of our users (“you,” “your,” “User”) under Nigeria’s Data Protection Act (NDPA) and other applicable international standards, including the General Data Protection Regulation (GDPR). This Privacy Policy describes how we collect, use, and disclose your personal information when you access and use our website, platform, and services.
1. Information We Collect
A. Personal Information You Provide
When you create an account, contact us, or engage with the Susumi platform, we may collect the following personal data:
- Identity Data: Name, age, nationality, and government-issued ID.
- Contact Data: Email address, phone number, and other contact details.
- Financial Data: Payment information, wallet addresses.
- Usage Data: Details about how you use our platform, including login history, and fund creation activity.
B. Automated Data Collection
We may collect information automatically through cookies and similar technologies:
- Technical Data: Device information, IP address, browser type, and usage data.
- Transaction Data: Details of transactions you carry out via the platform.
2. How We Use Your Information
We process personal information to operate and improve our services, in compliance with the NDPA’s principle of lawful processing:
- To Provide Services: Facilitate user accounts, transactions, and fund creation.
- For Communication: Respond to inquiries, send notifications, and provide customer support.
- To Improve Services: Analyze usage and technical data to enhance platform performance.
- For Security and Compliance: Monitor for fraud, enforce compliance with terms, and meet regulatory requirements.
- For Marketing: With your consent, send you promotional materials or special offers that may be of interest.
3. Sharing and Disclosure of Your Information
Susumi only shares your information under specific conditions to comply with NDPA’s data processing standards:
- With Third-Party Service Providers: We may share data with vendors who provide essential services, such as payment processing, analytics, and customer support, under strict contractual confidentiality.
- With Regulatory Authorities: We may share information as required to comply with laws, regulations, and enforceable governmental requests.
- During Corporate Transactions: In cases of business mergers, acquisitions, or asset transfers, personal data may be disclosed as part of the transaction.
4. International Data Transfers
Susumi may transfer, store, or process your data outside Nigeria, including in countries that may not have data protection laws equivalent to the NDPA. We ensure such transfers comply with NDPA by implementing safeguards like standard contractual clauses or obtaining your consent, as appropriate.
5. Data Retention
We retain your personal information only as long as necessary to fulfil the purposes for which it was collected, including for legal, accounting, or reporting requirements. Transaction and usage data may be anonymized and retained for historical and research purposes.
6. Security of Your Information
We implement industry-standard measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no electronic transmission or storage method is 100% secure, and we cannot guarantee absolute security.
7. Your Rights Under NDPA and GDPR
If you are a resident of Nigeria, the NDPA grants you the following rights:
- Right to Access: Request access to your personal data and obtain information on how it is processed.
- Right to Rectification: Correct inaccuracies in your personal data.
- Right to Erasure: Request deletion of your data under certain conditions.
- Right to Restrict Processing: Request limited processing under specific circumstances.
- Right to Data Portability: Request transfer of your personal data to another platform.
- Right to Object: Object to data processing in cases of legitimate interest or direct marketing.
- Right to Withdraw Consent: Where we rely on your consent for data processing, you may withdraw this consent at any time.
To exercise these rights, contact us at contact@susumi-nigeria.com.
8. Your Rights Under GDPR
If you are a resident of the EEA, you have the following rights:
- Right to Access: Request access to your personal data and obtain information on how it is processed.
- Right to Rectification: Correct inaccuracies in your personal data.
- Right to Erasure: Request deletion of your data under certain conditions.
- Right to Restrict Processing: Request limited processing under specific circumstances.
- Right to Data Portability: Request transfer of your personal data to another platform.
- Right to Object: Object to data processing in cases of legitimate interest or direct marketing.
To exercise these rights, contact us at contact@susumi-nigeria.com.
9. Cookies and Tracking Technologies
Susumi uses cookies and similar tracking technologies to enhance your experience, monitor platform usage, and analyze traffic. For information on how to control or disable cookies, refer to our Cookie Policy.
10. Children’s Privacy
Our services are intended for users over 18 years of age. We do not knowingly collect personal information from children under 18.
11. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of significant updates by posting the revised policy on this page or sending a notice to your registered email.
Cookies Policy
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Contact Us
For questions or concerns regarding this Privacy Policy and Cookies Policy or our data practices, please contact us at:
Email: contact@susumi-nigeria.com
Address:
Susumi Capital Index Ltd., Suite 3, 6th Floor, Nusaiba Plaza, Ahmadu Bello Way, Kado, Abuja, Nigeria